DIRECT EXAMINATION OUTLINE FOR YOUR OWN CLIENT

I have just returned from Hawaii where I took a deposition of my client because he has a fatal lung cancer and I wanted to perpetuate something of him by way of video deposition. Here is the basic outline I prepared, however the client has a tracheotomy and is unable to speak. He also has a serious hearing problem, both the result of over radiation for a head tumor. He is in bed at home and the only way to question him was to ask his wife the question who would repeat it through a hearing volume device. He would then write the answer on a pad and the wife would read it into the record. His medications made it difficult for him to function fully. As a result of all of this I elected to only ask three questions I selected from list of concluding questions at the end of the outline. I thought this outline might be helpful to you in creating your own direct examination of your injured client.

One Response to DIRECT EXAMINATION OUTLINE FOR YOUR OWN CLIENT

Great list. Approaching and sharing the info in this list with a jury can be made more interesting and persuasive by referring to exhibits and diagrams every 5-8 minutes. Just shared a short article about direct examination of an expert at my trial tips blog. Keep up the great work! Mitch